Section 10 - Monitoring
Minnesota’s Perkins V Monitoring Process
Minnesota State and MDE are required to monitor local Perkins consortia to assure compliance with fiscal and management requirements of the Strengthening Career and Technical Education for the 21st Century Act, the Minnesota 4-Year State Plan, as well as federal and state legislation and policy.
Monitoring also allows state staff to provide technical assistance, foster continuous improvement, and develop a better understanding of local performance, operations and issues facing CTE programs, schools and colleges.
Each consortium must provide evidence that the consortium is meeting the fiscal and programmatic requirements of the Perkins V Act and Minnesota Perkins requirements. State CTE staff meet with and provide technical assistance to local teams as they prepare for the monitoring interview. Monitoring guidelines and resources are available in the Consortium Monitoring Schedule and Resources section of the Coordinators' Portal.
- Determine present and predict future CTE program opportunities, challenges, and threats
- Identify factors that may enhance or detract from the availability of and access to high-quality CTE programs
- Review progress on identified student performance gaps and state-determined performance measures
- Monitor activities related to recruiting, retaining and training educational professionals
- Test the reliability of internal controls
- Verify that program objectives are being met
- Assure the reliability of the consortium’s financial and programmatic reports
- Examine if costs and services are allowable and eligible
- Development of a collaborative leadership team and decision-making process
- Status of programs of study
- Engagement in data-driven planning and decision-making in conjunction with the comprehensive local needs assessment
- Fiscal/financial responsibilities and cash management
A risk assessment tool is used to prioritize consortia to be monitored, as well as the level and frequency of monitoring to be performed. This risk assessment is based on the model utilized at the federal level by the OCTAE. The risk assessment reviews defining factors that may indicate excessive challenges to program implementation by the local consortia.
All Minnesota consortia will be monitored under Perkins V criteria and will continue to be monitored following the risk assessment process.
Potential risk factors to be assessed when determining consortia for monitoring include program performance, fiscal operations, and data reporting. In addition, the state may consider randomly selecting consortia to assure each consortium is monitored during the lifetime of the Perkins V Act. Risk assessment criteria include target areas that help identify changes critical to assessing the consortium’s risk level:
- Fiscal processes and patterns
- Targets met on performance indicators
- Evidence of data-driven decisions
- Evidence of unified planning and decision-making
- Stable leadership/governance
- Service to special populations
- State-recognized programs of study
The state may consider the use of additional information in assessing the sub-recipient’s risk level. Consortia may also request a monitoring visit or targeted technical assistance at any time.
Program Performance
Consortia may be identified for monitoring based on program performance. Consortia exhibiting excellent performance often provide valuable insight into how a consortium achieves goals and objectives in unique or innovative ways and what effective strategies are being used that may be replicable in other consortia. Consortia identified due to problems with performance could be chosen for monitoring because the consortium is having difficulty achieving goals and objectives, or because there are known compliance issues or fiscal improprieties that are identified from desk audit activities.
Data Reporting
In order to apply the risk factor selection criteria, current data must be available for each recipient. Therefore, if a consortium is unable to submit data such as enrollment figures or local plans and budgets, it becomes necessary for the consortium to be selected for a review.
Other Factors
Historical information, anecdotal information from employees, clients, and participants, and a variety of other factors may be appropriate in determining the sub-recipient’s need to be monitored.
Fiscal Analysis
Perkins monitoring must also examine several aspects of potential fiscal risk. Factors likely to prioritize a consortium’s selection for monitoring include:
- Recapture of a notably higher ratio of unspent funds
- A large total allocation
- Single audit findings from the Office of Management and Budget Circular A-133
A fiscal desk audit is part of every monitoring review. It's completed prior to the monitoring visit.
Minnesota State and MDE grant accountants will notify both secondary and postsecondary fiscal contacts identified in the approved consortium application of which transactions will be reviewed.
- Approximately 30 days prior to the monitoring visit, fiscal contacts will be notified of desk audit requests
- The fiscal contacts will provide all supporting documents to grant accountants within ten days of the request or ten days prior to the visit, whichever is sooner
- Supporting documents would include invoices, purchase orders, packing slips, special expense request forms, M16-A forms, employee expense forms, any notes and correspondence, and other relevant documentation related to the expenditure transactions
- Supporting asset documentation would include system- generated inventory reports, asset reconciliation reports, physical inventory reports, and evidence of asset tags
- The grant accountants will review the documentation and request any additional information if needed
- Within five days, the local consortium fiscal contacts respond and provide the additional information to the grant accountants
- Depending upon the above timeline, approximately five days prior to the visit, grant accountants will send preliminary findings to the fiscal contact, chief financial officer (CFO) and the monitoring team
- During the monitoring visit, a member of the monitoring team reviews any questions, findings and required corrective actions and timelines
- Any fiscal findings and corrective actions will be included in the final monitoring visit and audit report
- Within the timeline specified in the fiscal corrective actions, the fiscal contacts are to provide documentation of the completed corrective actions taken to the grant accountants and the monitoring team
- Run a query of all expenditure activity, including payment of invoices and correcting entries
- Provide a random sample of 3-5 percent of non-payroll transactions, depending on the volume of transactions, with a focus on larger transactions, and including at least one correcting entry
- Minnesota State and MDE will review documentation provided for:
- Completed, signed, and approved required documentation
- Invoices
- Encumbrances
- Special expense forms
- M16-A forms
- Consistency with state of Minnesota statutes, Minnesota State Board policies, MDE policies, and GASB/GAAP
- Perkins-eligible expenses
- Potential fraud
- Comparing equipment and asset reports to transactional activity
- Cash management patterns
What is the format for monitoring interviews?
Monitoring interviews will be conducted virtually unless a site visit is more appropriate, as determined by state staff. Virtual interviews requiree participants to have access to a quality internet connection. If an in-person visit is needed, state staff will work with consortium coordinatorrs on the scheduling logistics.
Who participates in the monitoring interview?
Participants in the meetings associated with consortium monitoring may vary depending on the governing and operating structure within a consortium. The secondary and postsecondary consortium coordinators will be interviewed by the monitoring review team consisting of Minnesota State and MDE staff. Secondary and postsecondary fiscal contacts should plan to be available during the interview in case questions arise or additional information is needed. Perkins coordinators may invite school district or college administrators to the introduction section of the interview and/or to the feedback meeting for review of the monitoring results. Administrators may include principals, superintendents, chief academic officers, chief student affairs officers, deans, and college presidents.
What evidence is needed and how does it need to be organized?
Collect evidence that documents consortium activities and compliance within the monitoring year using the Monitoring Criteria Guide provided in the Consortium Monitoring Schedule and Resources section of the Coordinators' Portal.